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SUNY Environmental Audit Update

SUNY Environmental Audit Update. SEHSA Corning November 2005. Barbara A. Boyle, CIH, CSP. EPA Project Coordinator State University of New York Office of the University Counsel boyleEHS @ aol.com. SUNY Programs. EPA Program Signed in April 2002 7 reports to date DEC Program

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SUNY Environmental Audit Update

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  1. SUNY Environmental Audit Update SEHSA Corning November 2005

  2. Barbara A. Boyle, CIH, CSP EPA Project Coordinator State University of New York Office of the University CounselboyleEHS @ aol.com

  3. SUNY Programs • EPA Program • Signed in April 2002 • 7 reports to date • DEC Program • Signed in February 2005 • 2 reports to date

  4. Inspections EPA Assigned SUNY “lowest priority” for five-years Exceptions include: citizen’s complaint, actual harm or imminent and substantial threat, criminal violation, or notification of spill; and oversight and confirmation DEC DEC will not inspect while auditors are on-site, except for conditions similar to above

  5. EPA Program Status(April 2002) Through Nov 2005, SUNY has reported: 35 campuses 7 disclosure reports 533 non compliances 514 corrected non compliances EPA has calculated waived penalties.

  6. DEC Program Status(February 2005) Through Nov 2005, SUNY has reported: 16 campuses 2 disclosure reports 132 non-compliances 123 corrected non-compliances Regional level awareness has been increasing.

  7. EPA Fines & Penalties(through May 2005 disclosure) Waived all economic benefit penalties. <$10K per violation, per campus Waived all gravity based penalties: $6.6M 27 campuses

  8. Reality Check One, open, unlabeled container of hazardous waste in hood. Possible violations @ $27.5K ea >>$82.5K: • Open container • Labeling missing • Treatment of HW

  9. EPA Waived Fines By Program • Air Programs – $2.2M • 86 violations @ 20/27 campuses (non-Title V) • Water Programs - $2.1M • 45 violations @ 9/27 campuses • RCRA/Universal - $1.5M • 158 violations @ 26/27 campuses • Oil and SPCC - $0.6M • 48 violations @ 20/27 campuses

  10. EPA Additional Info • Cost of correction • Scope of problem • Campus specific

  11. November 2005 Disclosure • Eight Campuses • Passed half-way point • Total EPA Violations: 84 • Corrected as of reporting date: 75 • Total State-Only Violations: 50 • Corrected as of reporting date: 44

  12. Violations by Program AreaNov 2005 Report

  13. Air Programs Reported by 24 of 35 campuses. Note: the SUNY EPA Agreement does not extend to most Title V permit conditions. Permit violations/Lack of or incomplete permits Parts washers, spray booths, emergency generators CFC management

  14. Water Reported by 11 of 35 campuses Stormwater issues ($$$) MS4, construction Only two items in last disclosure

  15. SPCC & Oil Reported by 27 of 35 campuses Secondary containment 55 gallons or more, including kitchen grease Issues with SPCC plans updated and complete, signed by PE

  16. Asbestos & Lead Reported by 13 of 35 campuses Lead notifications to tenants Asbestos NOIs and waste shipment records

  17. Hazardous Waste Reported by 34 of 35 campuses: • HW determinations • Containers and Labels • Contingency Planning • SAA Issues • Training of Personnel • On-site Batch Treatment • Manifests

  18. Universal Waste • Training • Closed containers • Labeling/Tracking

  19. DEC- Only Violations Air Programs • State level regs Oil Storage • PBS registration, inspections Pesticide • Certification/reporting issues RMW • Manifests, labeling, sharps

  20. Program Year 4May 05 – April 06 Disclosed November 2005: • Downstate • Optometry • Empire State • Adirondack • Columbia Greene • Corning • Hudson Valley • Tompkins Cortland

  21. Remainder of Year 4 • Stony Brook • Canton • Jefferson • Brockport • Genesee • Buffalo State • Niagara • Westchester (December audit) • Alfred (December audit) • Jamestown (December audit)

  22. Program Year 5 2006 Audit Dates • February Utica Rome, Herkimer, Mohawk Valley • April Fulton Montgomery, Schenectady, Broome • September Oswego, Onondaga, Cayuga • October Geneseo, Finger Lakes • December Morrisville, Oneonta

  23. Prevent Recurrence Reported to EPA • Violations and status • Method to remedy • Method to prevent recurrence • Documentation • Inspection Program • Environmental Management System

  24. Part II Pilot • System Administration Office of the University Auditor • Pilot Program limited to previously reported items

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